Marubeni

1. Sustainable forestry policy or commitment for all its operations?

The company has published a sustainable forestry policy which covers all operations.

2. Sustainable forestry policy or commitment applies to all suppliers?

The company has published a sustainable forestry policy which applies to all suppliers.

3. High-level position of responsibility for sustainability?

The company has established a Sustainability Management Committee, headed by the Chief Sustainable Development Officer. However, as this person is also on the Board of Directors, partial points have been awarded.

4. One or more members within the board of the company have responsibility for sustainability?

0 - Takayuki Furuya is the Chief Sustainable Development Officer (CSDO) and is also a board member.

5. Percentage or number of women in senior management team?

147 - The company reports 147 women in the senior management team.

6. Percentage or number of women board members?

1 - The company reports that there is one woman in its board of directors.

7. Member of multiple industry schemes or other external initiatives to reduce negative environmental or social outcomes associated with timber and pulp production?

[Externally verified] The company is a member of UNGC and FSC.

8. Collaboration with stakeholders to reduce negative environmental or social outcomes associated with timber and pulp production?

The company is a member of the Japan Foreign Trade Council (JFTC), supports the commitment to a Low-Carbon Society proposed by Keidanren, and takes part in the working groups and public meetings on climate change held by Keidanren and JFTC.

9. Sustainability report published within last two years?

The company's latest sustainability report was published in 2020.

10. Reports through standardised reporting systems?

The company submitted a CDP questionnaire in 2021.

11. Climate risks assessment available?

[Externally verified] The company reports a summary of climate risks and the potential impacts of climate change more generally. It has also submitted a CDP Climate questionnaire (2021) and reports that is in the process of conducting a rigorous climate risk assessment.

12. Natural capital assessment available?

13. Lists countries and operations?

The company's forest plantation business is conducted by two consolidated subsidiaries: WA Plantation Resources Pty. Ltd. (WAPRES) in Australia, and PT Musi Hutan Persada (PT-MHP) in Indonesia. It manages one pulp mill in Indonesia at PT. Tanjungenim Lestari Pulp and Paper, and two pulp mills in Japan, Koa Kogyo Co., Ltd. and Fukuyama Paper Co., Ltd., and a paper recycling business at Marubeni Paper Recycle Co., Ltd.

14. Lists countries sourcing from?

15. Total area of natural forest designated for wood/wood fibre production (ha)?

This indicator is disabled as the company reports that it only produces wood/wood fibre from plantations.

16. Total area of forest plantation (ha)?

140000 - In the company's 2019 sustainability report, it states that it owns 320,000 ha of gross project area, including 140,000 ha of tree plantations. Since the data is between two and five years old, partial points have been awarded.

17. Area of plantation/natural forest within outgrower schemes (ha)?

This indicator is disabled as the company reports that it does not source from outgrower smallholder suppliers.

18. Unplanted (areas designated for future development as plantation forest) (ha)?

19. Conservation set-aside area, including HCV area (ha)?

50189 - The FSC public summary reports of both subsidiaries provides figures for the total conservation area.

20. Area of Intact Forest Landscape (ha)?

This indicator is disabled as the company has reported or informed ZSL that it doesn't have any intact forest landscapes within its landbank.

21. Number of Forest Management Units (FMUs)?

2 - The company's 2 forest plantations are based across both subsidiaries, WA Plantation Resources Pty. Ltd. (WAPRES) in Australia and PT Musi Hutan Persada in Indonesia.

22. Maps of forest management units (FMUs)?

Maps for the company's subsidiary, PT Musi Hutan Persada, is published on Global Forest Watch, while the other subsidiary, WA Plantation Resources Pty. Ltd. (WAPRES), is reported through a static map. However, as these maps do not cover the company's whole operations, only partial points have been awarded.

23. Forest management plans available for all FMUs?

The company reports a forest management plan for WAPRES, but not for PT Musi Hutan Persada. Therefore, a partial score has been awarded.

24. Monitoring of forest management plan implementation available?

The company only reports monitoring of its forest management plan implementation for WAPRES and not for PT Musi Hutan Persada. Therefore, partial points have been awarded.

25. Company has provided valid legal documents to Open Timber Portal on use right (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

26. Company has provided valid legal documents to Open Timber Portal on forest management (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

27. Company has provided valid legal documents to Open Timber Portal on timber harvesting (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

28. Names and locations of all third-party supplying FMUs?

29. Number of company owned sawmills?

This indicator is disabled as the company reports that it does not own sawmills.

30. Names and locations of company owned sawmills?

This indicator is disabled as the company reports that it does not own sawmills.

31. Number of company-owned pulp and paper mills?

3 - The company controls one pulp mill through its subsidiary PT. Tanjungenim Lestari Pulp and Paper (Indonesia) and two paper mills through its subsidiaries Koa Kogyo Co. Ltd. and Fukuyama Paper Co. Ltd. (Japan).

32. Names and locations of company-owned pulp and paper mills?

The company provides the names and locations of its pulp and paper production units.

33. Reports total volumes (or percentages) sourced by company-owned sawmills that come from company's own operations and third-parties?

This indicator is disabled as the company reports that it does not own sawmills.

34. Reports total volumes (or percentages) sourced by company-owned pulp and paper mills that come from company's own operations and third-parties?

35. Number of third party supplying mills?

36. Names and locations of all third party supplying mills?

37. Reports total volume (or percentages) sourced from third-party supplying mills that come from the supplying mills' own operations and third parties?

38. Procedures to trace raw materials to country of harvest?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification.

39. Percentage of supply traceable to country of harvest?

40. Procedures to trace raw materials to FMU level?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification.

41. Percentage of supply traceable to FMU level?

42. Time-bound plan for achieving 100% third-party legality verification of FMUs or achieved?

The company reports that wood harvested from the plantations of WAPRES has obtained Forest Management Certification and Chain of Custody certification from the Forest Stewardship Council (FSC), and the other subsidiary, PT Musi Hutan Persada, is supplied by 100% certified wood and has obtained Forest Management certification from the Indonesian Forestry Certification Cooperation.

43. Percentage area (ha) verified as being in legal compliance by a third party?

100% - The company reports that as of 31st March 2021, wood harvested from the plantations of PT Musi Hutan Persada is supplied as 100% certified wood from IFCC. WAPRES is fully FSC certified in Australia and PT Musi Hutan Persada is fully IFCC (PEFC) certified in Indonesia.

44. Time-bound plan to source only wood/wood fibre that is in legal compliance verified by a third party?

The company commits to no handling of procured products produced from illegally logged timber, but does not have any dated targets or third party verification.

45. Percentage of all wood/wood fibre supply traded/processed verified as being in legal compliance by a third party?

46. Percentage area (ha) FSC FM certified?

58.5% - The company's subsidiary, PT Musi Hutan Persada, has an FSC FM certified area of 163,984.00 ha and WAPRES has an FSC certified area of 23,211 ha. Thus, 187,195 of company's total 320,000 ha landbank is certified.

47. Time-bound plan for achieving 100% FSC FM certification of FMUs or achieved 100% FSC-certification of FMUs?

48. Percentage of wood/wood fibre supply (tonnes) from all suppliers that comes from FSC FM certified areas?

49. Commitment to source only wood/wood fibre that meets FSC Controlled Wood and/or PEFC Controlled Sources requirements?

50. Percentage area (ha) PEFC certified (excluding FSC certified area)?

287333 (89.79%) - The company's Indonesian subsidiary, PT Musi Hutan Persada, is fully PEFC certified (287,333 ha) and the company's total landbank is 320,000 ha.

51. Commitment to zero conversion of natural ecosystems?

52. Commitment to zero conversion of natural ecosystems applies to all suppliers?

53. Commitment to zero deforestation?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification/membership.

54. Commitment to zero deforestation applies to all suppliers?

55. Criteria and cut-off date for defining deforestation and/or ecosystem conversion?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). As the policy requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's certification/membership.

56. Evidence of monitoring deforestation and/or ecosystem conversion?

WAPRES has released a monitoring report which shows areas affected by natural hazards or any conversion from the year 2016 to 2020, but no information is available for PT. Musi Hutan Persada. Thus, partial points are awarded.

57. Evidence of monitoring deforestation and/or ecosystem conversion in supplier operations?

58. Amount of deforestation and/or ecosystem conversion recorded in own operations since cut-off date?

59. Amount of deforestation and/or ecosystem conversion recorded in supplier operations since cut-off date?

60. Commitment to restoration of deforestation/conversion?

61. Commitment to restoration of deforestation/conversion applies to all suppliers?

62. Implementing a landscape or jurisdictional level approach?

[Externally verified] Points for external verification have been awarded on the basis of the company making this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2 EN) and the PEFC International Standard (PEFC ST 1003:2018). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC/PEFC certified landbank.

63. Biodiversity policy?

The company commits to protecting HCV forests from the viewpoint of biodiversity conservation, but does not provide any detail. Hence, partial points are awarded.

64. Biodiversity policy applies to all suppliers?

65. Identified species of conservation concern, referencing international or national system of species classification?

[Externally verified] Limited, externally verified points have been awarded on the basis of the company's FSC FM (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements do not fully meet the SPOTT indicator criteria.

66. Examples of species and/or habitat conservation management?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements fully meet the SPOTT indicator criteria.

67. Commitment to no hunting or only sustainable hunting of species?

68. Commitment to no hunting or only sustainable hunting of species applies to all suppliers?

69. Commitment to protect forest areas from illegal activities?

The company subsidiary, PT Musi Hutan Persada, commits to protecting forest areas from illegal harvesting only, hence partial points have been awarded.

70. Commitment to protect forest areas from illegal activities applies to all suppliers?

71. Evidence of protecting forest areas from illegal activities?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements fully meet the SPOTT indicator criteria.

72. Commitment to no use of genetically modified organisms?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification/membership.

73. Commitment to no use of genetically modified organisms applies to all suppliers?

74. Commitment to conduct High Conservation Value (HCV) assessments?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification/membership.

75. Commitment to conduct High Conservation Value (HCV) assessments applies to all suppliers?

76. High Conservation Value (HCV) assessments available?

[Externally verified] Company reports HCV assessments in its FSC public summary report.

77. High Conservation Value (HCV) management and monitoring plans available?

Company reports High Conservation Value (HCV) management and monitoring plans only for WAPRES.

78. Commitment to the High Carbon Stock (HCS) Approach?

79. Commitment to the High Carbon Stock (HCS) Approach applies to all suppliers?

80. High Carbon Stock (HCS) assessments available?

This indicator is disabled as the company reports that it only produces wood/wood fibre from natural forests.

81. Peer review of all High Carbon Stock (HCS) assessments undertaken since April 2015 by the HCSA Quality Assurance Process?

This indicator is disabled as the company reports that it only produces wood/wood fibre from natural forests.

82. Commitment to conduct social and environmental impact assessments (SEIAs)?

The company commits to conducting social and environmental impact assessments (SEIAs).

83. Commitment to conduct social and environmental impact assessments (SEIAs) applies to all suppliers?

84. Social and environmental impact assessments (SEIAs) available, and associated management and monitoring plans?

Company reports Social and environmental impact assessments (SEIAs) only for WAPRES unit in its plantation management plan.

85. Company has provided valid legal documents to Open Timber Portal on impact assessments (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

86. Commitment to no planting on peat of any depth?

The company commits to no planting on peatland.

87. Commitment to no planting on peat of any depth applies to all suppliers?

88. Landbank or planted area on peat (ha)?

89. Implementation of commitment to no planting on peat of any depth?

90. Commitment to best management practices for soils and peat?

The company commits to best management practices for soils and peat.

91. Commitment to best management practices for soils and peat applies to all suppliers?

92. Evidence of best management practices for soils and peat?

The company reports that it does not have operations on peatland. Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by PEFC.

93. Commitment to reduced impact logging?

This indicator is disabled as the company reports that it only produces wood/wood fibre from plantations.

94. Commitment to reduced impact logging applies to all suppliers?

95. Evidence of implementing reduced impact logging practices?

This indicator is disabled as the company reports that it only produces wood/wood fibre from plantations.

96. Commitment to zero burning?

The company commits to zero burning.

97. Commitment to zero burning applies to all suppliers?

98. Evidence of fire monitoring and management?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by PEFC.

99. Details/number of hotspots/fires in company FMUs?

100. Details/number of hotspots/fires in suppliers operations?

101. Time-bound commitment to reduce greenhouse gas (GHG) emissions intensity?

102. GHG emissions intensity?

The company reported GHG emissions for its entire operations as 1,0840 kilotons CO2 in 2020. However, the figure provided does not calculate intensity and is not specific to forestry operations.

103. GHG emissions from land use change?

This indicator is disabled as the company reports that it only produces wood/wood fibre from natural forests.

104. Progress towards commitment to reduce GHG emissions intensity?

105. Methodology used to calculate GHG emissions?

The company reports GHG Protocol Guidelines.

106. Time-bound commitment to improve water use intensity?

The company makes a commitment to ensure the effective and efficient use of water. However, this is not time-bound so only partial points have been awarded.

107. Water use intensity?

37 - The company reports the water consumption intensity of 37.00 (㎥/ton) for its pulp and paper production. But it is unclear if this covers the whole scope of forestry operations.

108. Progress towards commitment on water use intensity?

The company reports its yearly water consumption intensity figures for 2020-2021 but not 2019-2020. Therefore, partial points have been awarded.

109. Time-bound commitment to improve water quality (BOD or COD)?

110. Progress towards commitment on water quality (BOD or COD)?

111. Treatment of pulp and paper mill effluent?

The company reports the treatment of effluent from its paper making process for just one of its subsidiaries, Koa Kogyo pulp and paper mill.

112. Evidence of sawmill run-off containment and wastewater treatment?

This indicator is disabled as the company reports that it does not own sawmills.

113. Proportion of processing facilities with closed-loop water treatment system?

The company reports that Fukuyama Paper uses a closed-loop water treatment system. As this does not cover all operations, partial points have been awarded.

114. Commitment to protect natural waterways through buffer zones?

115. Implementation of commitment to protect natural waterways through buffer zones?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

116. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers?

The company provides a commitment to eliminate or minimise impacts arising from chemical use in its WAPRES plantation management plan, but this does not cover the company's entire operations. Thus, only partial points have been awarded.

117. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers, applies to all suppliers?

118. Evidence of eliminating chlorine and chlorine compounds for bleaching?

The company subsidiary, PT Tanjungenim Lestari Pulp & Paper, employs an elemental chlorine-free (ECF) bleaching pulp manufacturing process to reduce its impact on the environment. However, the information does not cover the company's overall operations, so only partial points have been awarded.

119. Commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides?

The company commits to not using World Health Organisation (WHO) Class 1A and 1B pesticides.

120. Commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides applies to all suppliers?

121. Commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention?

The company commits to not using Stockholm and Rotterdam Convention chemicals.

122. Commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention applies to all suppliers?

123. Chemical usage per ha or list of chemicals used?

The company subsidiary, WAPRES, reports a list of chemicals used through its FSC summary, but this does not cover all of the company's operations. Hence, partial points have been awarded.

124. Implementation of commitment to reduce chemical usage?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

125. Integrated Pest Management (IPM) approach?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

126. Waste management system in place to avoid negative impacts?

[Externally verified] Limited, externally verified points have been awarded on the basis of the company's FSC FM (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements do not fully meet the SPOTT indicator criteria.

127. Commitment to human rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification/membership.

128. Commitment to human rights applies to all suppliers?

The company makes a commitment that suppliers must respect human rights, but does not reference the Universal Declaration of Human Rights.

129. Progress on human rights commitment ?

The company reports that it runs training programmes on its Human Rights policy and published its human trafficking statement, including an explanation of training conducted for all employees.

130. Commitment to respect indigenous and local communities' rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification/membership.

131. Commitment to indigenous and local communities' rights applies to all suppliers?

132. Commitment to respect legal and customary land tenure rights?

The company commits to respect legal and customary land tenure rights but in relation to Free, Prior and Informed Consent (FPIC), so only partial points have been awarded.

133. Commitment to legal and customary land rights applies to all suppliers?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-40-004 V3-1). Full points have therefore been awarded for this indicator as 100% of the company's wood/wood fibre supply is FSC certified.

134. Commitment to free, prior and informed consent (FPIC)?

The company commits to Free, Prior and Informed Consent (FPIC).

135. Commitment to free, prior and informed consent (FPIC) applies to all suppliers?

136. Details of free, prior and informed consent (FPIC) process available?

137. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] Limited, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria.

138. Details of process for addressing land conflicts available?

139. Supports the inclusion of women across forestry operations, including addressing barriers faced?

[Externally verified] The company's subsidiary, WAPRES, has signed an industry association's diversity charter from the Australian Forest Products Association. However, these commitments do not apply to the group's entire forestry operations. Hence, partial points have been awarded.

140. Company has provided valid legal documents to Open Timber Portal on population rights (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

141. Commitment to enable sustainable use of non-timber forest products (NTFPs) by local communities?

This indicator is disabled as the company reports that it only produces wood/wood fibre from plantations.

142. Commitment to provide essential community services and facilities ?

The company commits to provide essential community services and facilities like employment opportunities, education, and community support.

143. Progress on commitment to provide essential community services and facilities?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC certified landbank.

144. Commitment to provide business/work opportunities for local communities?

The company commits to provide work opportunities for local communities.

145. Company has provided valid legal documents to Open Timber Portal on labour regulations (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

146. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification/membership.

147. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles applies to all suppliers?

The company's commitment to the ILO's Declaration on Fundamental Principles and Rights at Work applies to suppliers.

148. Progress on commitment to respect all workers' rights?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by either FSC or PEFC, whichever is highest.

149. Commitment to eliminate gender related discrimination with regards to employment?

The company commits to prevent employment and/or occupation-related discrimination based on gender.

150. Commitment to eliminate gender related discrimination with regards to employment applies to all suppliers?

151. Progress on commitment to eliminate gender related discrimination with regards to employment?

[Externally verified] Company reports on the details of progress regarding promoting opportunities for women in managerial positions, an innovation program that supports women in middle management to progress, and maternity support measures.

152. Percentage or number of temporary employees?

153. Percentage or number of women employees?

1186 (26.9%) - This figure refers to the percentage of female employees in 2021, across the company (Non-Consolidated).

154. Commitment to pay a living wage?

155. Commitment to pay a living wage applies to all suplliers?

156. Progress on commitment to pay a living wage?

157. Reporting of salary by gender?

158. Commitment to address occupational health and safety?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification.

159. Commitment to address occupational health and safety applies to all suppliers?

The company reports that its policy on occupational health and safety is applicable to its suppliers but does not refer to the ILO Code of Practice on Safety and Health in Forestry Work. Thus, only partial points have been awarded.

160. Provision of personal protective equipment and related training?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by PEFC.

161. Time lost due to work-based injuries?

0 - The figure given is for Marubeni Corporation as a whole. There was no lost time to work-based injuries.

162. Number of fatalities as a result of work-based accidents?

0 - The company reports that there were no fatal occupational accidents in 2021.

163. Commitment to support smallholders?

This indicator is disabled as the company reports that it does not source wood/wood fibre from smallholders.

164. Programme to support outgrower scheme and/or independent smallholders?

This indicator is disabled as the company reports that it does not source wood/wood fibre from smallholders.

165. Number or percentage of outgrower scheme and/or independent smallholders involved in programme?

This indicator is disabled as the company reports that it does not source wood/wood fibre from smallholders.

166. Process used to prioritise, assess and/or engage suppliers on compliance with company's policy and/or legal requirements?

The company reports its procedure for managing non-compliance in its Basic Supply Chain Sustainability Policy. This includes labour standards applicable to all its suppliers.

167. Number or percentage of suppliers assessed and/or engaged on compliance with company's policy and/or legal requirements?

The company reports that as of 31st March 2019, there were no business partners that did not comply with its supply chain labour standards. Information on compliance for other parts of the company's policies were not found, therefore partial points have been awarded.

168. Suspension or exclusion criteria for suppliers?

The company reports criteria for considering the exclusion of a supplier in relation to non-compliance with the labour standards.

169. Timebound action plans (including Key Performance Indicators) for suppliers to be in compliance with timber and pulp sourcing commitments?

170. Proportion of direct and indirect supply that comes from FMUs which are compliant with timber and pulp sourcing policies?

171. Commitment to ethical conduct and prohibition of corruption?

The company commits to ethical conduct and the prohibition of corruption.

172. Commitment to ethical conduct and prohibition of corruption applies to all suppliers?

The company reports a basic supply chain sustainability policy which provides commitments towards ethical conduct and the prohibition of corruption.

173. Progress on commitment to ethical conduct and prohibition of corruption?

174. Company has provided valid legal documents to Open Timber Portal on legal registration (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

175. Disclosure of the company’s management approach to tax and payments to governments?

The company reports its approach for tax payments to governments in the form of a tax policy.

176. Company has provided valid legal documents to Open Timber Portal on taxes, fees and royalties (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

177. Whistleblowing procedure?

The company reports its whistleblowing procedure, ensuring the protection of whisteblowers.

178. Own grievance or complaints system open to all stakeholders?

The company reports its complaint system via a compliance access point, but it is unclear whether this is accessible to external stakeholders.

179. Details of complaints and grievances disclosed?